LEGAL AID SERVICES OF OKLAHOMA, INC.

Finding 2022-002 ? Eligibility and documentation of Emergency Rental Assistance Program (ERAP) Criteria: Per the Compliance Supplement ? CFR 2 Part 200, assistance listing 21.023, under ERAP 1, housing stability services should include cases related to the COVID-19 outbreak and are intended to help keep eligible households stably housed. Condition: Case files relating to housing stability service applicants under ERAP 1 lacked sufficient documentation or self-attestation in LASO?s case management system for providing evidence of how COVID-19 resulted in the applicant?s financial hardship. Additionally, case files which were noted by LASO as not COVID-19 related but still assigned to ERAP 1, and documented financial hardship linked to no illness, health, or related COVID-19 impacts resulting in ineligible cases for ERAP 1. Cause and Effect: During the intake process COVID-19 related inquiries were left unanswered and/or the case management system was marked as COVID-19 related without any further documentation as to how the applicant was affected. As a result, incorrectly identified cases were assigned to the ERAP 1 grant and insufficient documentation existed. Questioned Costs: Unknown Recommendation: We recommend management provides additional training to intake staff as well as attorneys working on ERAP 1 cases to ensure a COVID-19 related link exists for the applicant and the casefile appropriately documents how COVID-19 resulted in financial hardship of the eligible household. Management Response: LASO agrees with the finding. LASO ERAP 1 (Emergency Rental Assistance Program) grant eligibility relied on the existence of a hardship directly or indirectly related to Covid. By comparison, LASO ERAP 2 grant eligibility relies more on financial hardship. LASO ERAP 1 funds were primarily earned by LASO through efforts to prevent the eviction of clients during the peak of COVID by LASO attorney presence at every FED docket. Many of the LASO eviction defenses were facilitated by the COVID eviction moratorium and the availability of additional ERAP 1 funds thru CCP (Community Cares Partners) to pay for both past and future rent for tenants directly or indirectly impacted by COVID. LASO agrees with the auditor?s finding that a portion of the sampled LASO ERAP 1 cases did not have clear documentation of how the client was impacted by COVID-19, though all cases were of an eligible type of case. The ERAP 1 grant has ended. For the ERAP 2 grant LASO has two grant managers to oversee implementation of the grant and provide training to staff on the eligibility requirements and documentation of such.